Well, I guess that is true if you plan on paying for a new battery. The only difference is a few extra adapter cables, which probably don't amount to much money. But, depending where you live, a 2011 or 2012 might be a better bargain if the battery degrades fast enough to warrant a free battery replacement. There were a few small tweaks to the battery chemistry in 2013, and depending where you live that could make the difference between qualifying for a new battery by 60,000 miles/60 months, or having to live with a degraded battery until you can afford to pay the $6000 out of your own pocket. In my opinion, I'm a little concerned that those chemistry tweaks really will do nothing in the long run except cheat more people out of a free 2015 battery replacement, as it may just slow the degradation slightly enough to get past the warranty period.
As I said though, it all depends where you live, how far your commute is, and how many miles you plan on putting on the Leaf per year. I'm in south Florida, and I wouldn't even consider a 2013 or 2014 because of my fear that it won't degrade fast enough to get the better chemistry replacement. There have been several posts on here recently of guys who have found cheap 2011 or 2012 Leafs that have lost 4 bars, or were close to it, thereby qualifying them for a new battery, which they got replaced free.
If you live in a cooler climate, and don't mind driving the Leaf until the battery degrades to the point you can't use it anymore, and you have budgeted in coughing up the $6000 for a new battery, go for it.